Budgeting and preparing for ISO27k

 

Are you responsible for your organisation's information risk and security or cybersecurity budget? Are you busily putting the finishing touches to your FY 2023 budget request?

Budgeting is a stressful management task, figuring out the figures and anticipating tough battles ahead leading (usually) to a disappointing outcome and yet more problems resulting from inadequate investment. With clear signs of another global recession looming (as if COVID, climate change and the war in Ukraine weren't challenging enough already), tightened belt-buckles are the order of the day*.

A substantial part of information risk and security expenditure is (whatever we may believe as professionals) discretionary. The decision to go for ISO/IEC 27001 certification, for instance, flows largely from management's appreciation of the business value of investing in information risk and security management good practices. There may be specific drivers such as incidents, compliance pressures or demands from business owners, partners and current or prospective customers, but even then there are numerous options and factors to consider such as:
  • The objectives for the Information Risk Management System - what it is expected to achieve for the organisation;
  • Your strategy for information risk, security, privacy, compliance, assurance and all that jazz, forming the picture into which the IRMS will slot neatly; 
  • How broadly or narrowly to scope the IRMS, and the rationale for that decision;
  • At what pace to implement the IRMS;
  • The implementation plan, preferably in detail for the first few months which probably means either drafting the architectural design or at least starting work on the specifications;
  • What resources to assign to the implementation: you'll need a suitable project manager and team, perhaps back-filling the information risk and security function until the IRMS is up to speed;
  • Priorities for this work relative to other business activities, objectives and requirements, making adjustments as necessary (both initially and as the project proceeds when stuff comes up);
  • Alignment with other corporate projects and initiatives e.g. exploiting strategic opportunities to update various systems, policies and processes for security and other reasons (such as Corporate Social Responsibility, or Governance, Risk and Compliance, or Environmental, Social and Governance, or some other Scrabble version) at the same time;
  • Change management aspects: does the organisation have the capacity and appetite to adopt and assimilate the IRMS, and to get the most value from it? Where are the likely speedbumps and roadblocks, and what can be done to smooth the way?
  • Project risks - assuming things may not go entirely to plan, look for alternative approaches/choices, contingency arrangements, dependencies and critical decision points (e.g. how far throgh the process can you book the certification audits?).
Identifying and addressing all that, and more, means a shed-load of work for management. Not only must cunning plans be developed, they must be 'sold' to senior managers responsible for the big decisions about strategies, budgets, resourcing etc. plus peers in other corporate departments/functions since we are all, in effect, competing for slices of the same pie.

An important preliminary step, then, is to convince senior management that a 'management system' or 'governance framework' for information risk and security is more than just a matter of best practices or compliance. It gives managers the information and levers necessary to direct, guide and monitor information risk and security, supporting and enabling the achievement of business objectives. An ISO/IEC 27001 certificate from an accredited certification body is like a stamp of approval ... but there's more to it. You'll find plenty of clues in our business case for an ISMS on how to persuade management that implementation makes sense for the business. 

* If budget requests are normally cut, anticipate even more savage cuts this time around despite the most robust and convincing case you can muster, due to the economic doom and gloom. Four useful budget negotiation techniques are:

(1) Being clear about your absolute bottom line, the point below which you might as well resign because you simply cannot achieve your obligations to the organisation; 

(2) Horse-trading with your peers to find win-win opportunities, goal alignment and complementary approaches (you scratch my back ...);
 
(3) Pulling strings - building strong relationships and understanding with powerful, influential managers with shared interests in this area; and

(4) Reminding managers (a.k.a. risk owners, asset owners ...) about their personal accountability in respect of protecting and exploiting information. If they consciously elect to under-fund security, they may be held to account for that business decision. 

Popular posts from this blog

Pragmatic ISMS implementation guide (FREE!)

Image
Early this morning ( very  early!) I remotely attended an ISO/IEC JTC 1/SC 27/WG 1 editing meeting in London discussing the planned revision of ISO/IEC 27003:2017 . Overall, the meeting was very productive in that we got through a  long  list of expert comments on the preliminary draft standard, debated the objectives of the project and the standard and reached consensus on most points. In summary: 27003 is to be revised to align with the current 2022 releases of ISO/IEC 27001 , 27002 and 27005 : These changes are  mostly  minor aside from the new section 6.3 on ISMS changes.
Read more

Two dozen information risks that ISO forgot

Image
Selecting the wrong controls - controls that are inappropriate, ineffective, too costly, impracticable, fragile, unnecessary, counterproductive or whatever, often as a result of blind faith in fads and fashions of the day and FOMO e.g. MFA, AI, cyber Failing to select the right controls - controls that are ideal for the particular situation, both now and in perpetuity, for whatever reason - mostly ignorance and prejudice Selecting and implementing controls at the wrong time or in the wrong way (where 'wrong' includes ineffective, inappropriate, sub-optimal e.g. bolting on controls rather than designing and building them in) Inept and inaccurate identification, analysis and quantification of risk, including reliance on p oor quality (incomplete, inaccurate, out of date, misleading, unreliable ...) information about actual risks, particularly subtle and emerging risks plus those involving deliberate concealment and misdirection e.g. fraud, misinformation, disinformation, propagan
Read more

Philosophical phriday - compliance risk

Image
According to a vendor's promotional video interview I saw recently, the 'cybersecurity compliance burden' has allegedly become so significant that [customer] organisations are eagerly buying [their] software tools and services to help them manage and fulfil their obligations. The vendor's argument goes that, instead of accumulating a ragtag bunch of policies and other controls relating to user Identification and Authentication (I&A), for instance, it makes sense to:  Identify all the cybersecurity-related laws, regulations and standards that apply to the organisation; Examine them for any security control requirements relating to, say, I&A; Rationalise the I&A controls down to the smallest set that satisfies all the requirements - the lowest common denominator; Design, implement, use, manage and maintain those I&A controls; Have the I&A controls checked or audited to gain assurance that the compliance requirements are met.  OK so far? Sounds reasonab
Read more

ISMS internal audit priorities

Image
A thread on the ISO27k Forum sparked my imagination over coffee this morning. Hope had previously asked for assistance with an ISO/IEC 27001:2022 audit plan.  Bhushan offered a lengthy and generally sound response explaining how to use a spreadsheet with tabs to plan and record the audit work performed on 100% of the main body clauses and 50% of the 93 Annex A controls, day-by-day. That's OK ... except it wasn't entirely clear that he was interpreting and elaborating on the standard's actual requirements. ISO/IEC 27001 does not explicitly require, for example, that (as Bhushan stated) "ALL the management system clauses from 4 to 10 AND their sub-clauses need to be listed and audited" in an ISMS internal audit, although evidently he interprets it in that way. In clause 9.2.1, the standard states a requirement for internal audits to provide information on whether the ISMS conforms to the organization’s own requirements for the ISMS plus the requirements of the stan
Read more

Reading between the lines of ISO27001 [L O N G]

Image
ISO/IEC 27001 is a succinct, formally-worded standard for two key reasons: It is deliberately generic, being applicable to all manner of organisations regardless of difference in location/s, size, industry, maturity, structure, information risk and security status ... and so on. In effect, it specifies the lowest common denominator - the things that ALL organisations should be doing to manage their information security controls, as a minimum. The hurdle is set low enough that every organisation ought to find value in designing, implementing and operating an I nformation S ecurity M anagement S ystem as laid out in the standard. It is a certifiable standard, explicitly specifying the characteristics that every certified organisation's ISMS is expected to have. Again, it is a minimal specification with no concept of typical, average or maximum security: that is entirely down to the organisations themselves to determine, following the information risk management processes minimally de
Read more

Passionate dispassion

Image
Someone who is actively involved in, or is managing, an activity is patently not independent of it. They may well make a conscious, rational and determined effort to be objective, dispassionately reviewing evidence etc ., but their subconscious/emotional biases/prejudices and beliefs/value-systems will inevitably influence what they do. With the best will in the world, they will struggle to challenge and assess their past decisions and activities, especially if they were "certain" or "determined" or genuinely believed they were "doing the right thing". Furthermore, it is very hard for anyone to review the things they did not do, decisions they did not make or options they did not even consider. Mostly, they remain out of sight or out of the question.
Read more

45 ISO Management Systems Standards

Image
The ISO website  currently lists 45 published M anagement S ystems S tandards: 1. ISO 7101:2023 Healthcare organization management — Management systems for quality in healthcare organizations — Requirements 2. ISO 9001:2015 Quality management systems — Requirements 3. ISO 10012:2003 Measurement management systems — Requirements for measurement processes and measuring equipment 4. ISO 13485:2016 Medical devices — Quality management systems — Requirements for regulatory purposes 5. ISO 14001:2015 Environmental management systems — Requirements with guidance for use 6. ISO 14298:2021 Graphic technology — Management of security printing processes
Read more

Philosophical phriday - a noncompliance ramble

Image
In a previous philosophical phriday post , I moaned about vendors of security compliance support/management tools and services over-promising and under-delivering - an admittedly biased, even cynical opinion piece about the compliance imperative . A recent article in Corporate Compliance Insights notes that "CISOs are not just defenders against cyber threats but also champions of compliance and operational resilience". Hmmm, are CISOs 'compliance champs', really? Today, I'm discussing alternatives to being compliance-driven. How else can organisations drive their information risk, security and related concerns in a positive direction?
Read more

Adaptive SME security Crowdstrike special

Image
As if on cue, along comes a golden opportunity to consider what the Adaptive SME security  approach has to say regarding the Crowdstrike incident: That's not 20/20 hindsight but foresight: I've picked out the most relevant rows from the security controls table published in the guide 24 hours before the incident.  Although Crowdstrike primarily supplies much larger enterprises than SMEs, the incident could equally have afflicted other security software, or indeed operating systems such as Windows and assorted cloud apps commonly used by SMEs. Regardless of the details, it is a wake-up call, an opportunity to consider and respond to the information risks ... and to adapt , accordingly.
Read more